Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 513

Received: 21/12/2023

Respondent: NHS Black Country Integrated Care Board

Agent: Winterburn Heritage & Planning

DLP8:
The Black Country ICB commissions healthcare services in Dudley. The ICB brings NHS services together locally to improve population health and establish shared strategic priorities. Services provided by an ICB include the following:
GP services
Pharmacies
Community health services
Mental health services
Adult social care
Voluntary organisations
Further to this, GP surgeries are grouped into Primary Care Networks (PCNs) serving populations generally of between 30,000 and 50,000 registered patients, enabling greater provision of coordinated and integrated health and social care. PCNs therefore by necessity span larger geographies to meet the needs of communities, including areas beyond Dudley's Boundaries.
The ICB supports the Local Plan Policy intention to promote the health & wellbeing of Dudley's local communities, and require the assessment and mitigation of development proposals on the above services.

Support

Representation ID: 514

Received: 21/12/2023

Respondent: NHS Black Country Integrated Care Board

Agent: Winterburn Heritage & Planning

DLP9:
The ICB supports the Health and Wellbeing section of the Local Plan in its expression of stakeholders committing to change at a whole systems level and to working together to achieve a sustainable and resilient Dudley, with citizens involved at every level of governance for health and wellbeing. This can be achieved by determining the right proportion of resource that is committed to delivering prevention, treatment and care for health and wellbeing through the following:

The first priority should be to addressing the integration of health and care systems. It includes harnessing the available information and intelligence into a more complete picture. This will strengthen the relationships between the organisations involved, to develop more seamless and co-ordinated responses to health and wellbeing needs. It will also ensure that the community gets the best value and outcomes possible from the local health care economy and infrastructure.
A commitment to addressing improvements to the determinants of health within Dudley such as housing, education, employment, active lifestyles and transport.
Enabling a population that is equipped with the right skills to be informed about health, care and wellbeing and also be able to access and navigate systems to appropriate self-care or services for themselves and others.

In summarising the key health impacts identified through the Policy drafting process, the ICB is of the opinion that the Draft Dudley Local Plan makes a positive contribution to addressing the identified health issues. Policy DLP9 Healthcare Infrastructure in particular is supported for recognising the connection between housing development, local population change and their potential impact on the Primary and Secondary Healthcare Network.

DLP9(4)- Support

DLP9 (5)- In respect of DLP9 (5), it is acknowledged that developer contributions can affect the financial viability of certain developments and will therefore not always be appropriate or reasonable to apply. The ICB would not wish to support the imposition of a regime that would see the viability of development compromised by such contributions.
However, based on an independent viability assessment, the ICB suggests that developer contributions for Healthcare infrastructure could be deferred or discounted where this would not make the development unacceptable in planning terms. This would retain a degree of flexibility in applying the standard contributions/charges where affordability based on development viability is clearly demonstrated, without compromising the planning necessity for identified infrastructure and facilities.
Where developer contributions are deferred the ICB would support Dudley Council potentially applying clauses in Planning Obligations relating to deferred contributions, which will seek to recover all or part of the discount in circumstances where the financial climate and economic viability of the development improves. Here, any recaptured discount will be limited to the full standard developer contributions for the Healthcare infrastructure applicable at the time the planning obligation for a development was signed.

The ICB also supports paragraph 7.24 of the Supporting Text and its requirement for Applicants to consult the ICB in advance of the submission of a planning application where a significant amount of housing is to be provided.
The ICB also supports the intention to produce separate guidance as part of an SPD, on the methodology used for calculating the appropriate level of developer contributions.

Comment

Representation ID: 720

Received: 20/12/2023

Respondent: NHS Black Country Integrated Care Board

We are generally supportive of the local plan to which i have attached our latest draft health care infrastructure SPD, (we understand the forthcoming change to the SPD Process) for your consideration